1
Achieving Legacy System Retirement and
Data Consolidation
Session 184, February 13, 2019
Lisa Stump, SVP and CIO, Yale New Haven Health
Bill Hudson, ACIO and VP of IT Operations, John Muir Health
2
Lisa Stump
Has no real or apparent conflicts of interest to report.
Bill Hudson
Has no real or apparent conflicts of interest to report.
Conflict of Interest
3
• Learning objectives
• Background
• Deciding on an archive strategy
• The path to success
• Principles of archiving: what to archive
• Data governance: structure for a plan
• Engaging Operations: foundation for a plan
• Recommendations and lessons learned
Agenda
4
• Illustrate the advantages and challenges of consolidating legacy
data in a central archive
• Illustrate how to build the business case for legacy system
retirement and consolidation of legacy data into an active archive
• Define the organizational roles to involve in the process to achieve
successful adoption of a solution
• Define the critical principles of legacy data consolidation and
legacy system decommissioning and discuss how to apply them
• Show the lessons learned from a legacy data consolidation and
retirement program
Learning Objectives
5
Drivers for Enterprise Legacy
Retirement & Archiving
Healthcare Market Transformations
• Federal mandates
ICD-10
Meaningful Use
• Acquisitions and mergers
• Budgetary pressure to consolidate
applications
• Data-driven healthcare
• Streamline, Simplify, Save
Legacy Application
Replacement &
Retirement
6
Drivers for Enterprise Legacy
Retirement & Archiving
• Compliance: 7 – 28 years
• Continued need for access to clinical
data
• Revenue cycle: billing continues
• Audits: RAC, Medicare, Medicaid,
commercial carriers
• Research
• Cost of maintaining legacy
applications
• Data spread over disparate systems
Legacy Retirement
Active Archiving
7
Enterprise Legacy Landscape at
JMH
• Reviewed all 500 of our applications
• Identified 162 candidates
• Worked with key staff to identify data elements to retain and
applications to decommission
• We focused for 3 – 3 ½ months on the “Legacy Application
Decommissioning Assessment”
8
Enterprise Legacy Landscape at
YNHHS
• Prioritized legacy clinical and revenue cycle applications post-
EMR consolidation
• Timing based on data size and legacy maintenance cost
• Worked with key staff to identify data elements to retain
• Emphasized clinical benefit of extending longitudinal record back
in time
9
Why use an enterprise, centralized,
active archive?
Reduce data footprint through selective archiving
Create single point of access/retrieval
Maintain data usability
10
Active vs. Static Archive
Will the data be accessed often?
Examples: HIM staff responding to ROI requests;
Billers accessing for billing functions;
HR staff responding to audits;
Clinicians accessing clinical records
Is seamless access via other applications important or
beneficial?
Example: Access lab records held in the archive via the new EMR
If YesIf Yes ActiveActive
11
Use Cases & Secondary Use
• Archive used for day-to-day functions
Release of Information
Revenue cycle, billing
Patient care
HR functions
• Archive used to mine data for special requests, such as CDC
study requests
12
Archiving Options Considered
• Expensive and difficult to manage
Retain the legacy
system
• Non-compliant, high risk, and expensive
Decommission the
legacy system and
destroy data
• Print to paper, archive to PDFBackup raw data
• Static
• Active
Enterprise archive
with end user GUI
13
Why We Used an Enterprise Active
Archive
• Not a “typical” archive
• Includes workflow functionality
Billing accounts for active A/R (2+ years after last DOS)
Release of Information
Interoperability
• Allows for real-time end user access
• Reporting
• Discrete data elements and document images
• Secondary use of data
• Consistent workflow
14
The Path to Success
• Building a business case
• Establishing data governance
• Engaging stakeholders
• Overcoming archiving challenges
• Project planning
• Choosing the systems to retire
• Choosing the data to archive
• Moving quickly to ensure adoption
• Communicate, Communicate, Communicate
15
Critical Success Factors
• Achieve leadership support for sun-setting all applications
Involve department leadership to avoid resistance to
decommissioning
• Successful data migration into active archive completed before
decommissioning – key dependency
• Teamwork
Utilize efforts among many departments instead of
maintaining dedicated resources
• Technology
Active archive, ability to handle required workflow
• Effective communications
Scope is broad and timeline is long
16
Building a Business Case
Use Cases
Revenue Cycle Clinical
Data
Retention
Guidelines
Reimbursement/payment
history records: 10 years
Master patient index/visit
history: permanently
Adult records: 10 years
from most recent visit
Minor records: 28 years
Use Cases
Billing accounts; payment
posting
Financial reporting
Interface with billing
systems
Insurance & cash
collections
RAC audit responses
Physicians need to
reference for point of care
clinical history
HIM staff ability to
respond to ROI requests
17
Building a Business Case
Expected components of cost savings
Software support fees (top priority)
Hardware support fees
Internal support/help desk staff
Hardware refresh
Data center costs
18
Building a Business Case
Annual Cost Savings
$0
$500,000
$1,000,000
$1,500,000
$2,000,000
$2,500,000
$3,000,000
$3,500,000
1 2
Pre-project legacy costs Post Project Costs
Annual Savings
Yale
JMH
19
Yale
JMH
Annualized Legacy Support Fees only
$2,980,000
$2,780,000
Annualized Active Archive fees/costs
(Including new equipment)*
$326,000
$304,000
Net Savings
$2,654,000
$2,476,000
Additional cost savings not calculated:
• Net hardware refresh & data center costs
• Net savings on internal support/help desk staff
* For Yale, no new equipment; for JMH, new hardware figured into
self-hosted datacenter costs; Cost of learning new system:
negligible, easy to use.
Building the Business Case
Illustrate Savings with ROI Analysis
20
What to Archive
Workflow and User Access
No workflow,
no GUI
No workflow,
no GUI
Replicate legacy
look, feel, and
workflow
Replicate legacy
look, feel, and
workflow
0% 100%
Seek a balance based on need of
specific data set.
We retained essential workflow as
determined by end users and
governance group.
21
What to Archive
Amount of Data to Retain
Discard all data from
applications
Discard all data from
applications
Keep all data from
applications
Keep all data from
applications
0% 100%
Seek a balance based on need
of specific data set.
Legal and Compliance agree on
data to retain.
22
Enterprise Data Governance
Model employed at Yale New Haven Health
• All projects led through IT, providing consistent leadership
• IT had over-arching responsibility for selecting applications to
retire and data to be retained, with input from business units
and compliance
• SMEs from the business units performed data validation and
software testing/acceptance
• SMEs who knew the legacy systems but had moved on to
analyst roles within the organization were tapped for the
enterprise archiving project
23
Enterprise Data Governance
Model employed at John Muir Health
• Governance board developed that selected applications to retire
and data to retain
Comprised of Compliance, Legal, IT, HIM, Revenue Cycle,
Clinical
Needed guidance and buy-in by all data stakeholders
• IT led the projects, with SMEs for testing and validation
• JMH employs an active archive expert who knows and supports
the enterprise archiving system, just like any other major
application
24
Engaging Operations
Evaluating Data for Enterprise Archiving and
Applications for Retirement
• Legacy application-specific
questionnaire completed
for each application (JMH)
• RFP conducted for
archiving options
• Confirmed data retention
periods through Legal,
HIM, and Compliance sub-
committees
• Project planning prioritized
based upon cost reduction
and contractual obligations
Stakeholders
Clinical
HIM
Research
Legal
Compliance
Revenue
Cycle
25
• Types of questions: how the information was used, any reporting
needs, their perception/interpretation of what the future
requirements would be
• Who was interviewed: direct operational users and their
supervisors
• Departments:
– HIM: any legal medical record retention requirements
– Legal: regulatory/legal considerations
– Compliance: any retention requirements related to HIPAA
and other regulations
– Treasury: advise regarding the financial systems
Interviewing Operations
26
Business Engagement
Legacy Retirement Planning Discussions
Stakeholders
Clinical
HIM
Research
Legal
Compliance
Revenue
Cycle
• Set expectations: not an
identical replication of the
legacy application
• Involved operations team in
archive decision
• Decided on an Active
Archive
27
Project Overview
Next phase after new HIS
An active archive was selected to address the following requirements:
• Provides longitudinal patient records that indicate original legacy
system
• Supports EMR integration – patient context viewing
• All YNHHS financial data will remain in an “active” state (complete
billing functionality) to accommodate compliance, billing, and
collection functions for a minimum of ten years
• All YNHHS clinical data will be available to providers, auditors, and
researchers for a minimum of ten years
• Meets ITS security and infrastructure standards
• Enables retirement of legacy systems post migration to the active
archive, realizing cost savings
28
Overcoming Enterprise Archiving
Challenges
• As an enterprise program, projects are rolled out over time
• Worked with vendor to test and stage the data ahead of
migrating it into the database, minimizing any downtime
• Managing end user expectations
Actual needs, define use cases
Central v. local storage
Archive will not replicate legacy system
29
Enterprise Archive Cycle
Determine which applications to decommission
Discovery
• WHO: Involve business unit leadership, Compliance, Legal
• WHEN: Shortly after selection of new HIS
• WHAT: Set criteria, identify use cases for legacy data: clinical, revenue
cycle, ERP
Choose technology and service – Enterprise Active Archive
Solution
• Involve business units in decision
• Get a “partner” to help solve problems; technology to manage workflow
Plan retirement phases
Planning
Migrate data to Enterprise Active Archive & Retire Legacy Apps
Implement
• Phased in over several years
Active Archive Progression at YNHHS
SCM
Jan ‘16
Cerner
Sept ‘16
3M
Chartview
Oct ‘17
Centricity
EMR
Sept ‘17
QuadraMed
InteGreate
(McKesson)
HAC
(Horizon
Amb Care -
McKesson)
Med-
Informatix
Medipac
Feb ‘16
SDK
July ‘16
Meditech
May ‘18
Clinical Data (read only)
Financial Data (read/write)
31
Enterprise Active Archive
Integration with new EMR
Easy access to legacy data from
within new EMR under the
navigator section “PreEpicEMR”
32
Quick Adoption
Uneventful go-live – no calls from users, including physicians
The Active Archive was easy to use
• Configured for end users
• Use cases were satisfied
Stakeholders were included in the selection and implementation
process
33
• Start early – ideally at the same time as selection of new HIS or
during merger
• Include the business unit stakeholders: Revenue Cycle, Clinicians,
HIM, Finance/HR, IS
• Manage expectations within the organization with a clear vision,
project plan, and budget
• Engage in data retention ‘roadmapping’
• Set expectations early – active archive vs. the legacy applications
• Ensure a successful program with your own internal project
manager/coordinator
• Ensure data validation beyond a simple record count test
Recommendations/Lessons Learned
